Acheiving Compliance Through People

5
ACHIEVING COMPLIANCE THROUGH PEOPLE: TRAINING SUPERVISORS TO TACKLE PROCEDURAL NON-COMPLIANCE Paul Leach 1 , Jonathan Berman 1 and David Goodall 2 1 Greenstreet Berman Ltd, London, UK 2 National Grid, UK All organisations face the challenge of improving compliance. For many, the challenge is increased by the nature of the workforce, which may be both constantly changing, and working away from a xed location. In such circumstances, there is signicant reliance on local supervision to control the work, and instil the necessary culture and attitudes. For such organisations, it is apparent that the local supervisor is a key element in any compliance enhancement process. Over the last two years Greenstreet Berman has been developing a programme to help a national utility organisation tackle procedural team non-compliance through the effective development of supervisors. The programme has led to the creation of a Supervisor Development Centre. This centre focuses on providing supervisors with the leadership and supervisory skills to ensure they can effectively identify, challenge and rectify team procedural non-compliance while on site and thus improve the overall safety of operations. The development centre looks at procedura l non-compliance relating both to occupation al health and safety and to process safety. A key element of the approach is to use picture-based and live mock-up scenarios to help supervisors practice their skills and allow an assessment of competence to take place, which can feed into on-going competence management arrangements. The overall approach recognises that each supervisor comes not only with different levels of ‘compliance managemen t competence’, but also with different interpersonal skills and approaches. Consequently the development centre is oriented around enabling participants to understand and recognise their own strengths and limitations, as well as recognising positive and negative beha- viours in the staff they are supervising. This paper discusses the developmen t and implementation of the supervisor development centre. The paper will briey summarise the background to the development of the centre, detail the meth- odology used to identify relevant competencies and training requirements , describe the centre aims and content and nally provide some indication of the value of the centre, based on anecdotal par tic ipa nt fee dback . It wil l dra w out the imp lic ati ons for any or gan isa tion tha t wis hes to enhance compliance. KEYWORDS: Training, Competen ce Management, Leadership, Supervis ion INTRODUCTION Pro cedural compli ance is an ess ent ial ele ment of saf ety manage ment, in ter ms of occ upa tion al hea lth and saf ety and process safety and business management, in terms of improving performance, enhancing reputation and reducing costs (i .e. cost s associ at ed wi th re-wor k, damag e to mate rials and other assets, and those tha t can arise from incidents and accidents). However the ef fec tive management of pro cedura l complia nce is a signicant cha llen ge and organisations need solutions that provide long-te rm sustai nable improve- ment. To do this, there needs to be a move away from focus- ing solely on surface issue solutions such as procedural and task re-design and start to consider how an organisation can foster and install positive safety behaviours in their teams. Ind eed for thi s to occ ur the local sup ervi sor becomes a key elemen t in the enhancement of compli ance, as for many organisations, site teams change regularly and work away from a xed location. Resea rch indicates that the supervisor plays a crucial role in the management of team safety, a key element of whi ch is pro cedural complia nce. 1 Eff ective super vision has been shown to have a positive and long lasting effect on team performance, compliance, injury rate, delays and costs. 2,3 This is essen tially because supervisors have the gre atest opport unity to inuence tea m behavi our , and throug h their own behaviour, foster and instil the necessary culture and attitudes within their teams. It is theref ore in recogn ition of the crucia l role super- visors play, that Greenstreet Berman Ltd in collaboration with National Grid have developed the Supervisor Develop- ment Centre, to hel p superviso rs develop the ski lls the y requir e to succe ssfull y tackle procedural non-compli ance through fostering and installing positive safety behaviours in their teams. 1 HSE (1999) Effective Supervisory Safety Leadership Behaviors in the Offs hore Oil and Gas Industr y. 2 Greenstreet Berman (2008) Managing Driver Managers. 3 Rai l Saf ety and Sta nda rds Boa rd (2009) Understanding Human Factors. SYMPOSIUM SERIES NO. 156 Hazards XXII  # 2011 IChemE 168

description

Complinance

Transcript of Acheiving Compliance Through People

7/18/2019 Acheiving Compliance Through People

http://slidepdf.com/reader/full/acheiving-compliance-through-people 1/5

ACHIEVING COMPLIANCE THROUGH PEOPLE: TRAINING SUPERVISORS TO TACKLE

PROCEDURAL NON-COMPLIANCE

Paul Leach

1

, Jonathan Berman

1

and David Goodall

2

1Greenstreet Berman Ltd, London, UK 2National Grid, UK 

All organisations face the challenge of improving compliance. For many, the challenge is increased

by the nature of the workforce, which may be both constantly changing, and working away from a

fixed location. In such circumstances, there is significant reliance on local supervision to control the

work, and instil the necessary culture and attitudes. For such organisations, it is apparent that the

local supervisor is a key element in any compliance enhancement process.

Over the last two years Greenstreet Berman has been developing a programme to help a national

utility organisation tackle procedural team non-compliance through the effective development of 

supervisors. The programme has led to the creation of a Supervisor Development Centre. This

centre focuses on providing supervisors with the leadership and supervisory skills to ensure they

can effectively identify, challenge and rectify team procedural non-compliance while on site and

thus improve the overall safety of operations.The development centre looks at procedural non-compliance relating both to occupational health

and safety and to process safety. A key element of the approach is to use picture-based and live

mock-up scenarios to help supervisors practice their skills and allow an assessment of competence

to take place, which can feed into on-going competence management arrangements.

The overall approach recognises that each supervisor comes not only with different levels of 

‘compliance management competence’, but also with different interpersonal skills and approaches.

Consequently the development centre is oriented around enabling participants to understand and

recognise their own strengths and limitations, as well as recognising positive and negative beha-

viours in the staff they are supervising.

This paper discusses the development and implementation of the supervisor development centre.

The paper will briefly summarise the background to the development of the centre, detail the meth-

odology used to identify relevant competencies and training requirements, describe the centre aims

and content and finally provide some indication of the value of the centre, based on anecdotalparticipant feedback. It will draw out the implications for any organisation that wishes to

enhance compliance.

KEYWORDS: Training, Competence Management, Leadership, Supervision

INTRODUCTION

Procedural compliance is an essential element of safety

management, in terms of occupational health and safety

and process safety and business management, in terms of 

improving performance, enhancing reputation and reducing

costs (i.e. costs associated with re-work, damage to

materials and other assets, and those that can arise from

incidents and accidents).However the effective management of procedural

compliance is a significant challenge and organisations

need solutions that provide long-term sustainable improve-

ment. To do this, there needs to be a move away from focus-

ing solely on surface issue solutions such as procedural and

task re-design and start to consider how an organisation can

foster and install positive safety behaviours in their teams.

Indeed for this to occur the local supervisor becomes a

key element in the enhancement of compliance, as for

many organisations, site teams change regularly and work 

away from a fixed location.

Research indicates that the supervisor plays a crucial

role in the management of team safety, a key element of 

which is procedural compliance.1 Effective supervision

has been shown to have a positive and long lasting effect

on team performance, compliance, injury rate, delays and

costs.2,3 This is essentially because supervisors have the

greatest opportunity to influence team behaviour, and

through their own behaviour, foster and instil the necessary

culture and attitudes within their teams.

It is therefore in recognition of the crucial role super-visors play, that Greenstreet Berman Ltd in collaboration

with National Grid have developed the Supervisor Develop-

ment Centre, to help supervisors develop the skills they

require to successfully tackle procedural non-compliance

through fostering and installing positive safety behaviours

in their teams.

1HSE (1999) Effective Supervisory Safety Leadership Behaviors in the

Offshore Oil and Gas Industry.2Greenstreet Berman (2008) Managing Driver Managers.3Rail Safety and Standards Board (2009) Understanding Human

Factors.

SYMPOSIUM SERIES NO. 156 Hazards XXII   # 2011 IChemE

168

7/18/2019 Acheiving Compliance Through People

http://slidepdf.com/reader/full/acheiving-compliance-through-people 2/5

RATIONAL FOR THE SUPERVISOR

DEVELOPMENT CENTRE

Over the past few years National Grid has been implement-

ing a compliance management improvement program across

the organisation to improve the level of compliance withengineering standards and safe working practices. Their

key objectives are to:

.   Ensure public safety – this includes immediate public

safety when carrying out work in areas where

members of the public could be affected e.g. signage,

lighting and guarding issues;

.   Improve process safety – this refers to the quality and

integrity of work carried out e.g. pipework is replaced

according to procedures to ensure that it has the

desired integrity and is not at risk of failure sooner

than expected;

.   Ensure employee health and safety – risk of injury/

death (e.g. slips, trips, falls etc.).

National Grid recognised that supervisors are

pivotal in improving standards and compliance as they

have direct influence on teams and consequently required a

solution to be focused at this level to ensure that supervisors

have the necessary skills to effectively lead and manage their

teams to ensure team compliance with National Grid engin-

eering standards and safe working practices. Moreover,

National Grid required a solution that provide sustainable

long-lasting results and that would have a observed positive

benefits on performance, reputation and cost.

Greenstreet Berman was commissioned by National

Grid to provide overall support on the compliance

program and to specifically develop the Supervisor Devel-opment Centre. This is because Greenstreet Berman has

considerable experience of supporting compliance improve-

ment programs and developing safety leadership and behav-

ioural safety training, that provide sustainable safety and

business improvements.

DEVELOPMENT OF THE CENTRE

The centre was developed from three approaches – job

analysis workshops, training review and stakeholder discus-

sions – along with Greenstreet Berman’s general expertise

in safety leadership issues. This triangulation of approaches

was applied to ensure the course was built around the

specific requirements of National Grid and key competen-cies required for supervisors to effectively tackle team

non-compliance.

JOB ANALYSIS WORKSHOPS

Two job analysis workshops were carried out with National

Grid supervisors. Each workshop had approximately 8–10

supervisors and lasted a full day. Supervisors were selected

from across the organisation to ensure diversity within the

sample.

The objectives of the workshops were to:

.   Understand the context and current roles of the supervi-

sors;

.   Identify supervisor perceptions of their current role and

key priorities;

.   Identify key tasks and behaviours associated with good

and poor performance;

.   Identify training already provided – particularlyelements identified as being particularly good or poor;

.   Identify real and perceived barriers to compliance –

both for teams and supervisors.

TRAINING REVIEW

A training review was carried out to understand the type

of training provided to supervisors and the general structure

of the training packages currently being delivered. The

review was carried out through discussions with the training

department around the types of training provided and a

review of several different training packages.

STAKEHOLDER DISCUSSIONSA number of stakeholder discussions were held with key

members of the compliance improvement strategy team.

The discussions were used to help identify what National

Grid required from the course, that is, what was the per-

ceived success criteria and what type of information was

required from the course in terms of assessment of compe-

tence. The discussions were also used to help National Grid

think about and identify the types of competencies and

behaviours they expected from supervisors that could then

be integrated into the course.

FINDINGS

The job analysis workshops, training review and stake-holder discussions highlighted a number of key findings:

.   The role of the supervisor was revealed as being

complex with many differing, and potentially competing

priorities. There was an apparent lack of clarity on

National Grid’s expectation on the key priorities and

activities;

.   Supervisors recognised safety as a key part of their

responsibilities but had received little if any training

on safety leadership;

.   Three key supervisor competencies were identified for

the successful management and enhancement of team

non-compliance:

W

  Observation – accurate identification and under-standing of non-compliance on site;

W   Challenging – confidence and motivation to chal-

lenge all non-compliances identified on site, remain-

ing in control of interactions with teams, setting

clear expectations of behaviour and ensuring

that corrective action is taken to rectify the non-

compliance;

W   Coaching – effective questioning and listening

to help teams understand and identify for them-

selves non-compliances, consequences of the non-

compliance and required corrective actions.

.   Current training combined both presentation and pra-

ctical elements. Training packages that were highly

SYMPOSIUM SERIES NO. 156 Hazards XXII   # 2011 IChemE

169

7/18/2019 Acheiving Compliance Through People

http://slidepdf.com/reader/full/acheiving-compliance-through-people 3/5

interactive and practical were considered to be the most

successful programs. However the majority of training

provided related to technical and process knowledge

and practice and not safety leadership and safety

management;.   National Grid required a program that firstly helped

develop the competence of supervisors but also provided

an assessment of performance and competence to aid

further development activity once the supervisor had

finished the course.

These findings were used to develop and structure the

course aims and content.

AIMS OF THE DEVELOPMENT CENTRE

Thekey aimof thedevelopment centre is to allow supervisors

to learn, practice and develop the key competencies needed

to effectively tackle and enhance team non-compliance, in

a supportive environment where they can receive feedback 

on their performance from their peers and the facilitators.

Indeed it is for this reason that the training package

has been titled a “development centre” as opposed to a train-

ing course. This is because a “development centre” is a

specific type of training event that uses a package of 

inputs, exercises and scenarios that simultaneously assess

an individual’s performance and provide development

opportunities to meet a required level of competence.

The specific aims of the centre are to:

.   Help supervisors clearly understand their role and

responsibilities as supervisors;

.   Enhance the supervisor’s ability to influence team beha-

viours to stop non-compliance and thus perform through

their teams (through observation, challenging and

coaching);

.   Allow supervisors to practice these competencies and

learn from their peers in a supportive environment;

.   Identify on-going development needs.

STRUCTURE OF THE DEVELOPMENT CENTRE

The development centre is structured into several

components – pre-course work, during the centre and post

course continuous learning.

PRE-COURSE WORK 

Research indicates that manager feedback and the use of 

self-reflective questionnaires can help learners identify

current strengths and weakness in their style of working

and supervision.4

Therefore before taking part in the development

centre each supervisor is required to complete pre-course

work. This consists of completing a leadership impact ques-

tionnaire, which takes around 30 minutes. An individual lea-

dership impact report is generated for each supervisor and

used within the centre to help supervisors think about

their leadership style and its impact on team performance.

The supervisor’s line manager is also requested to

provide feedback on the supervisor’s performance to help

the supervisor during the development centre think aboutareas of strength and weakness and identify relevant devel-

opment steps to improve performance.

DURING THE CENTRE

The centre lasts 2  12

 days and is structured around the learn-

ing cycle, combining both input sessions and practice ses-

sions, with feedback to enhance the learning experience of 

delegates. This has been shown to be a very effective

method for learning and development.5

 Input sessions   – throughout the 2  12

 days a range of 

input sessions are provided, using Powerpoint and group

based activities. These sessions last around 20 minutes to

an hour depending on topic and cover areas such as:.   Roles and responsibilities of supervisors;

.   Coaching for compliance;

.   Leadership and safety leadership (structured around the

leadership impact report and manager feedback);

.   Risk based decision making (using picture based exer-

cises of non-compliance);

.   Challenge, interacting and providing feedback (using

video clips, pictures of non-compliance, group exer-

cises);

.   Risk assessment (key component involves a risk assess-

ment using the PTW for deep excavation);

.   Setting standards and influencing people – (particularly

focus on why people do not comply, supervisor beha-viours that can influence non-compliance and the key

opportunities supervisors have to influence their teams);

.   Time management;

.   HSE responsibilities – based around a video interview

of a supervisor who was involved in an HSE investi-

gation.

Picture based scenarios  – the picture based scenarios

are a key component of the development centre and allow

the supervisor to practice the required competencies

within a realistic setting.

For each picture based scenario session (initial site

inspection, return site inspection, team brief and individual

coaching) supervisors are split into two groups of four, withone facilitator per group. Within each group an individual

will be selected to play the role of the supervisor for the

scenario, two other group members will be selected to

play the team and one group member will be required to

play the observer. The individual playing the supervisor is

given some pictures of non-compliance that represents the

team’s job. The supervisor and team are required to act as

though they are on-site. The supervisor is required to

rectify the situation and the individuals playing the team

are provided with role play instructions and encouraged

to be challenging. The scenario usually runs for about4Doyle (2003) Work and Organizational Psychology. An Introduction

with Attitude.   5Buckley and Caple (2004) The Theory and Practice of Training.

SYMPOSIUM SERIES NO. 156 Hazards XXII   # 2011 IChemE

170

7/18/2019 Acheiving Compliance Through People

http://slidepdf.com/reader/full/acheiving-compliance-through-people 4/5

5–10 minutes until the situation is resolved or reaches a

natural conclusion.

During the scenario the facilitator observes the super-

visor’s behaviour and uses a set of detailed observation cri-

teria to help make notes on key behaviours exhibited by thesupervisor during the scenario.

Once the scenario has finished each group member

provides feedback on the supervisor’s performance, high-

lighting strengths and development areas. The facilitator

then provides feedback based on their observations.

The whole process is then repeated using different

pictures until all members of the group have played the

role of the supervisor.

Each picture based scenario session increases with

difficulty as the centre continues, i.e. for each session super-

visors are expected to apply more sophisticated behaviours

to help tackle the problem. This therefore allows supervisors

to apply skills and increase competence as the centre

progresses.

 Live mock-ups –   the development centre is run at the

National Grid Skills Development Centre in Hitchin which

has the facility to run live mock-ups of deep excavations,

service connections and street walkthroughs. Live mock-

ups are therefore used within the centre to provide a

further opportunity for supervisors to practice skills and

receive feedback on performance.

Six live mock-up sessions are carried out within the

centre:

.   Two deep excavation sessions with non-compliances

relating to trench support, PPE and PTW;

.   Two service connections with non compliances relating

to pipe integrity;

.   Two initial site briefing walkthroughs.

The live mock up sessions are structured exactly the

same as the picture based scenario sessions but use real-

live mock-ups to make the situation as real as possible.

This has proven to be very useful in providing a more

testing challenge, particularly on observation skills, than

the picture based scenarios. Additionally, the supervisors

like the more realistic site situation.

POST COURSE CONTINUOUS LEARNING

Research indicates that learning and development inter-

ventions often fail to produce long term benefits becauseorganisations do not implement effective processes and

systems to support continuous learning and development.6,7

Therefore after the development centre a develop-

ment needs report is developed for each supervisor who

has attended the centre. This report collates the facilitator’s

observations of the supervisor’s performance and behaviour

during the course, particularly within the scenarios.

The report is broken down into five sections:

–   Demonstration of the key competencies – for each of the

key competencies (observation, challenging and coach-

ing) a performance rating is given (well above

minimum, satisfactory or needs improvement), along

with information on strengths, development areas and

recommended actions to help enhance performance on

that key competence.

–   Leadership style  – the leadership impact report is sum-

marised to help the line manager and supervisor clearly

understand the supervisor’s leadership style and the

impact, both positive and negative, the style can have

on team performance.

–   Attitude on course   – a summary is provided of the

supervisor’s attitude on the course, whether they

engaged with the material, were keen to learn, etc,

thus providing an indication of their aptitude for learn-

ing and willingness or resistance to change.–   Overall comment  – an overall comment is provided for

the supervisor based on all observations during the

course. This essentially summarises the previous sec-

tions, particularly their observed level of competence

demonstrated on the course and their attitude.

–   Mentoring activities   – a list of relevant mentoring

activities is provided based on the observations of per-

formance, identified development needs and rec-

ommended actions to improve performance. The aim

of this section is to provide the supervisor’s manager

with ideas and guidance on how they can help the super-

visor continue to develop and improve once they are

back in the workplace.

The key aim of the report is to facilitate and help the

manager and supervisor identify and implement mentoring

and development activities to ensure the supervisor can con-

tinue to learn, develop and improve. Moreover, information

within the report is only based on observations during the

centre and hence the managers are encouraged to use the

reports in conjunction with other relevant performance

data to help identify development and mentoring activities.

REPORTED BENEFITS

The supervisor development centre has been running

since September 2008 (progressively improving as timepasses) and is now a key component of the National Grid

compliance improvement program, providing a unique

and powerful way of helping to improve procedural com-

pliance. The development centre does this by providing

supervisors with the opportunity to acquire, practice and

apply the skills and behaviours needed to positively influ-

ence teams understanding of, and behaviour to, procedural

compliance.

Feedback from participants of the centre has been

overwhelmingly very positive. Participants have felt that

the centre provides the key skills needed to help tackle

team non-compliance and allows supervisors to not only

practice these skills in realistic situations but also learn

6Doyle (2003) Work and Organizational Psychology. An Introduction

with Attitude.7Buckley and Caple (2004) The Theory and Practice of Training.

SYMPOSIUM SERIES NO. 156 Hazards XXII   # 2011 IChemE

171

7/18/2019 Acheiving Compliance Through People

http://slidepdf.com/reader/full/acheiving-compliance-through-people 5/5

from their peers and learn how other supervisors tackle situ-

ations, thus helping to give supervisors greater confidence

in interacting and dealing with teams who are not complying

with National Grid engineering standards and safe working

practices.Indeed Greenstreet Berman Ltd recently assisted a

National Grid Alliance in identifying and evaluating the

impact of the Supervisor Development Centre. The review

has currently identified the following key business impacts:

.   Supervisors have increased confidence in their role;

.   Supervisors are stopping unsafe jobs more often because

they are not only more confident of when they should

stop a job but more confident that they will be supported

in doing so;

.   Improved compliance across Occupational Health and

Safety and Process Safety measures and belief that the

course will help to sustain this improvement;

.   Application of a standardised approach to supervision of teams across the alliance.

The above business impacts are all enablers to

improved safety performance and reductions in accidents

and incidents, thus highlighting the potential impact the

supervisor development centre can have on bottom line

business and safety results.

APPLICATION OF APPROACH

The Supervisor Development Centre can be applied to any

high hazard operational environment where operations are

carried out by teams and require supervision. Moreover,

this work demonstrates supervisors play a critical role in

facilitating long-lasting improvements in compliance and

other relevant business areas and therefore any organisation

looking to improve procedural compliance would benefit

from interventions that aim to help supervisors practice

and develop the necessary skills to foster and install positiveteam behaviors.

Indeed the approach and structure of the development

centre highlights several key learning points, that should be

considered by organisations wishing to develop these type

of interventions:

1. Structuring the intervention around the key skills and

knowledge expected of supervisors to foster positive

safety behaviors, identified through job analysis work-

shops, is essential for ensuring the intervention has

maximum affect;

2. Pre-course feedback and assessments are very effective

methods for helping supervisors consider strengths and

weakness of their supervision style;3. Interventions should be built around the learning cycle,

providing opportunities for theory, practice and feed-

back, helping to cement learning into practice;

4. Use of picture based scenarios and where possible

live mock-ups, allow the supervisor to practice the

required competencies within a realistic setting and

provide a very effective approach to learning and

development, through practice, feedback and peer

learning;

5. Systems for continuous learning should be in place

to ensure development and improvement continues.

Providing development reports after a training interven-

tion can help facilitate this process and provide the

foundations for continued development.

SYMPOSIUM SERIES NO. 156 Hazards XXII   # 2011 IChemE

172